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No max penalty Willful neglect Must authorize and define the use of PHI in contracts w/ partners 10% reduction in Medicare reimbursements if organization is not HIPAA compliant Subtitle D of HITECH is Privacy

Dis-incentives in latter years of HITECH for non-Meaningful Users www.hipaasurvivalguide.com

[WSJ, 02/02/09] [ITRC] Notices must be sent within 60 days Over-rides FTC Red Flags

administrative, physical and technical BA’s are now within the jurisdiction of HHS Goes into effect on 02/18/2010 Reduces the risk on CEs (by shifting some of it to BAs)